Delhi High Court Quashes FIR Following Amicable Settlement Between Parties.

Headnote:

The Delhi High Court quashed an FIR registered under various provisions of the Bharatiya Nagarik Suraksha Sanhita, 2023 after noting that the dispute between the complainant and the accused had been amicably settled. The Court emphasized that continuation of criminal proceedings in such circumstances would amount to an abuse of process and that the inherent powers of the High Court could be exercised to secure the ends of justice.

Background:

1. FIR No. 469/2024, dated 22 September 2024, was registered at P.S. Gandhi Nagar, District Shahdara, Delhi, under Sections 332(c), 324(4), 351(2), 115(2), and 3(5) of the Bharatiya Nagarik Suraksha Sanhita (BNS).
2. The complaint alleged that on 21 September 2024, the petitioners forcibly entered the complainant’s shop, fought with staff, damaged property, and assaulted workers.
3. During pendency of the case, the parties amicably settled their dispute and executed a Compromise Deed dated 16 January 2025.
4. Both sides appeared personally before the Court and confirmed the voluntary nature of the settlement. The complainant (Respondent No. 2) raised no objection to quashing the FIR.

Court’s Observations:

1. The Court relied on Gian Singh v. State of Punjab (2012) 10 SCC 303, where the Supreme Court recognized that continuation of criminal proceedings despite settlement may amount to abuse of process if the dispute has been resolved amicably.
2. The Court reiterated that under Section 482 Cr.P.C., inherent powers can be invoked to prevent abuse of process or secure the ends of justice, even in non-compoundable offences, citing B.S. Joshi v. State of Haryana (2003) 4 SCC 675.
3. Observing that the parties had settled their dispute without coercion and continuation of proceedings would serve no purpose, the Court deemed it appropriate to quash the FIR.

Legal Provisions Discussed

1. Section 528, Bharatiya Nagarik Suraksha Sanhita, 2023 – Transfer and inherent powers.
2. Section 482, Criminal Procedure Code (Cr.P.C.) – Inherent powers of the High Court.
3. Gian Singh v. State of Punjab (2012) 10 SCC 303.
4. B.S. Joshi v. State of Haryana (2003) 4 SCC 675.

Conclusion:

The Court quashed FIR No. 469/2024 and all proceedings arising therefrom, subject to the petitioners depositing ₹ 15,000 with the Delhi State Legal Services Authority within one month. The petition and all pending applications were disposed of accordingly.

Citation: 2025:DEL:783

Case: Aman Chopra & Ors. v. State (NCT of Delhi) & Anr.

Court: High Court of Delhi at New Delhi

Coram: Hon’ble Mr. Justice Ravinder Dudeja

Date of Decision: 3 November 2025

Criminal Miscellaneous Case No.: CRL.M.C. 783/2025 & CRL M.A. 3710/2025